Botox and the need for more regulation

The government must address the gaps in the UK’s regulatory framework for cosmetic procedures meaningfully and urgently, writes
Hugh Whittall; while
Linda Theobald says the NHS should not pick up the pieces because of people’s vanity

DHSC claims to have put in place “stronger regulations” for such procedures since the 2013 Keogh report publicised shocking gaps in patient protection. The Nuffield Council’s own report in 2017 reinforced Keogh’s concerns, and raised more of its own – not least with respect to children’s access to these procedures. However, no regulation has changed as a result.

The “robust” qualifications that DHSC refer to are entirely voluntary: there is nothing to stop someone with no qualifications from offering invasive non-surgical procedures. The provision of Botox and dermal fillers is not covered at all by the Care Quality Commission (the CQC’s “new powers to rate cosmetic surgery clinics” apply to surgical procedures only). The products used – particularly dermal fillers – are equally unchecked by the law: anyone can make and market dermal fillers; and anyone can inject them, wherever they choose – in hotel rooms, living rooms or garages. (Regulation of these products as “medical devices” is being developed by the EU but will not be implemented until after Brexit.)

The lack of regulation around invasive non-surgical cosmetic procedures is an issue that will not go away, and their use is still growing. This raises real concerns for the safety of the increasing number of people who seek these procedures. Rather than adopting a disingenuous approach to the “protection” offered in the UK at the moment, the government must address the gaps in the UK’s regulatory framework for cosmetic procedures meaningfully – and soon.Hugh WhittallDirector, Nuffield Council on Bioethics

• I am rather fed up with people expecting the government or the NHS to regulate and pick up the pieces because of people’s vanity. If they want to abuse their bodies in such a way, then they should be responsible for the outcome, nobody else. These clinics are not forcing them to have such procedures.Linda TheobaldLondon